Item8TomNananClachExtensionCommitteeReport

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 8 24/06/2022

CAIRNGORMS NATION­AL PARK AUTHORITY

DEVEL­OP­MENT PRO­POSED: Tom nan Clach wind farm extension

Con­sulta­tion from Scot­tish Gov­ern­ment Energy Con­sents and Deploy­ment Unit

REF­ER­ENCE: 2022/0135/PAC (ECU00003453)

APPLIC­ANT: Infinergy

DATE CON­SUL­TED: 6 April 2022

RECOM­MEND­A­TION: Split recom­mend­a­tion: No objec­tion to pro­pos­al and exist­ing and con­sen­ted wind farms, but Objec­tion if Leth­en wind farm gains consent

CASE OFFICER: Nina Caudrey, Plan­ning Officer (Devel­op­ment Plan­ning and Envir­on­ment­al Advice)

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 8 24/06/2022

PUR­POSE OF REPORT

1. The pur­pose of this report is to inform the com­mit­tee decision and sub­sequent con­sulta­tion response to the Scot­tish Gov­ern­ment Energy Con­sents and Deploy­ment Unit (ECDU) on an applic­a­tion sub­mit­ted under Sec­tion 36 of the Elec­tri­city Act 1989 for a pro­posed wind farm loc­ated to the north of the Cairngorms Nation­al Park. The Scot­tish Gov­ern­ment are the determ­in­ing Author­ity for this applic­a­tion as the out­put is more than 50 MW. The applic­a­tion is accom­pan­ied by an Envir­on­ment­al Report (ER), which presents the find­ings of the applicant’s Envir­on­ment­al Impact Assess­ment (EIA).

2. The plan­ning issues to be con­sidered are con­fined to the effects of the pro­posed wind farm on the land­scape char­ac­ter and Spe­cial Land­scape Qual­it­ies (SLQs) of the Nation­al Park. All oth­er mat­ters, such as eco­logy, noise, gen­er­al amen­ity, etc, are assessed by the decision maker (Scot­tish Min­is­ters) with advice from stat­utory consultees.

3. Under the cur­rent work­ing agree­ment on roles in land­scape case­work between NatureScot and the Park Author­ity, NatureScot lead on the pro­vi­sion of advice on the effects on the SLQs caused by pro­pos­als out­with the Cairngorms Nation­al Park. Their advice has been used to inform this report.

SITE DESCRIP­TION AND PRO­POSED DEVELOPMENT

1. The pro­posed wind farm exten­sion would be loc­ated imme­di­ately south of the adjoin­ing exist­ing Tom nan Clach wind farm, at approx­im­ately 5 kilo­metres (km) north-west of the closest part of the Nation­al Park bound­ary, as shown in the applicant’s fig­ure 9.12 on page 2 of this report.

2. The exist­ing wind farm com­prises 13 tur­bines at 125 metres to tip height. The pro­posed exten­sion would com­prise 7 tur­bines with a max­im­um height of 149.9m to the tip of the blade in an upright pos­i­tion, and asso­ci­ated infra­struc­ture (such as a bor­row pit, under­ground cabling, sub­sta­tion, bat­tery stor­age, etc).

3. The pro­posed devel­op­ment would make use of the exist­ing infra­struc­ture for the exist­ing Tom nan Clach wind farm where pos­sible, includ­ing the site entrance and access track from the B9007. Approx­im­ately 4km of new access track would be required to install and main­tain the exten­sion turbines.

4. The pro­posed wind farm would have an estim­ated total installed capa­city of around 31.5MW depend­ing on the tur­bine spe­cific­a­tion used. (Because the pro­posed devel­op­ment is an exten­sion to the exist­ing Tom nan Clach wind farm, the com­bined gen­er­at­ing capa­city is over 50MW, there­fore fall­ing with­in the threshold for con­sulta­tion by ECDU/​determination by Scot­tish Government.)

5. The­or­et­ic­al vis­ib­il­ity of the pro­posed wind farm from with­in the Nation­al Park is shown by the applicant’s Zone of The­or­et­ic­al Vis­ib­il­ity fig­ure (Appendix I). When con­sid­er­ing the cumu­lat­ive visu­al effects, the green and blue shown in the applicant’s cumu­lat­ive Zone of The­or­et­ic­al Vis­ib­il­ity fig­ure (Appendix II) demon­strates that vis­ib­il­ity of the pro­posed wind farm from with­in the Nation­al Park. Much of where it would be seen from is already influ­enced by vis­ib­il­ity of a num­ber of oth­er exist­ing and con­sen­ted wind

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item Item 8 24/06/2022

farms (the com­bined vis­ib­il­ity shown in green). There are some areas (shown in blue) with­in the Nation­al Park where it would intro­duce vis­ib­il­ity of a wind farm where cur­rently there is none.

1. Visu­al­isa­tions from sev­en view­points were provided in the applicant’s ER that demon­strate the pre­dicted level of vis­ib­il­ity that would be had from within/​on the bound­ary of the Nation­al Park: a) VP2 Carn Glas-choire, approx­im­ately 5km from the closest tur­bine. b) VP3 Ptar­mig­an lodge, Cairngorm moun­tain, approx­im­ately 32km from the closest tur­bine. c) VP4 Cre­agan a Chaise, Crom­dale hills, approx­im­ately 25km from the closest tur­bine. d) VP7 Geal Charn Mor, Mondah­liath, approx­im­ately 22km from the closest tur­bine. e) VP9 Meall a Bhua­chaille, approx­im­ately 25km from the closest tur­bine. f) VP12 Gor­ton Hill above Grant­own, approx­im­ately 5km from the closest tur­bine. g) VP16 Cre­ag Ealraich, on the A939 approx­im­ately 8km from the closest turbine.

2. The visu­al­isa­tions asso­ci­ated with each view point are avail­able to the pub­lic by search­ing the applic­a­tion doc­u­ments on the ECDU web­site https://www.energyconsents.scot/ApplicationDetails.aspx?cr=ECU00003453 for the rel­ev­ant fig­ures: a) Vol 3 Fig­ure 9.42 View­point 2 Carn Glas choire b) Vol 3 Fig­ure 9.43 View­point 3 Ptar­mig­an Lodge c) Vol 3 Fig­ure 9.44 View­point 4 Cre­agan a Chaise Hills of Crom­dale d) Vol 3 Fig­ure 9.47 View­point 7 Geal Charn Mor Mon­adh­liath e) Vol 3 Fig­ure 9.49 View­point 9 Meall a Bhua­chaille f) Vol 3 Fig­ure 9.52 View­point 12 Gor­ton Hill g) Vol 3 Fig­ure 9.56 View­point 16 Cre­ag Ealraich

REL­EV­ANT PLAN­NING HISTORY

1. PRE/2021/0014 in April 2021 CNPA respon­ded to a scop­ing con­sulta­tion from ECDU for the cur­rent application.

PLAN­NING POLICY CONTEXT

1. The pro­posed devel­op­ment is loc­ated wholly out­with the Nation­al Park, there­fore the Cairngorms Nation­al Park Loc­al Devel­op­ment Plan policies do not apply. How­ever, an assess­ment of the pro­pos­al must have regard to Scot­tish Plan­ning Policy (SPP) and the Nation­al Park Part­ner­ship Plan (NPPP).

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item Item 8 24/06/2022

Nation­al Policy

1. Scot­tish Plan­ning Policy sets out nation­al plan­ning policies that reflect Scot­tish Min­is­ters pri­or­it­ies for the devel­op­ment and use of land, as well as for oper­a­tion of the plan­ning sys­tem. The con­tent of SPP is a mater­i­al con­sid­er­a­tion in plan­ning decisions that car­ries sig­ni­fic­ant weight.

2. Policy relat­ing spe­cific­ally to Nation­al Parks and devel­op­ment man­age­ment can be found in para­graphs 84 and 85 of SPP. These re-state the four aims of the Nation­al Parks as set out in the Nation­al Parks (Scot­land) Act 2000, as well as the need to pur­sue these col­lect­ively. SPP high­lights that if there is a con­flict between the first aim (con­serving and enhan­cing the nat­ur­al and cul­tur­al her­it­age of the area) and any of the oth­ers, then great­er weight must be giv­en to the first aim. Plan­ning decisions are expec­ted to reflect this weight­ing and be con­sist­ent with the four aims.

3. Para­graph 85 of SPP also cla­ri­fies that the aims and require­ments of para­graphs 84 and 85 apply to devel­op­ment out­with a Nation­al Park that affects the Park.

4. Para­graph 212 of SPP states that ​“where devel­op­ment affects a Nation­al Park… it should only be per­mit­ted where: a) the object­ives of the des­ig­na­tion and the over­all integ­rity of the area will not be com­prom­ised; or b) any sig­ni­fic­ant adverse impacts on the qual­it­ies for which the area has been des­ig­nated are clearly out­weighed by social, envir­on­ment­al or eco­nom­ic bene­fits of nation­al importance”.

Stra­tegic Policy

1. The Cairngorms Nation­al Park Part­ner­ship Plan (NPPP) 2017 – 2022 is required under sec­tion |1 of the Nation­al Parks (Scot­land) Act 2000. It is the man­age­ment plan for the Cairngorms Nation­al Park approved by Scot­tish Min­is­ters. The NPPP sets out how all those with a respons­ib­il­ity for the Nation­al Park will coordin­ate their work to tackle the most import­ant issues. There is a duty for decision makers to have regard to the NPPP, a require­ment set out in Sec­tion 14 of the Act. As such, the NPPP is a mater­i­al con­sid­er­a­tion in plan­ning decisions.

2. The NPPP iden­ti­fies that the land­scapes of the Nation­al Park are val­ued by many and under­pin the area’s eco­nomy. It con­tains policies to safe­guard land­scape interests. Of rel­ev­ance to wind farm devel­op­ment pro­pos­als are policies 1.3 and 3.3.

3. Policy 1.3 seeks to con­serve and enhance the SLQs. Policy 3.3 seeks to sup­port devel­op­ment of a low car­bon eco­nomy and increase renew­able energy gen­er­a­tion where this is com­pat­ible with con­serving the SLQs. In rela­tion to wind farm devel­op­ment, the policy states that ​“large scale wind tur­bines are not com­pat­ible with the land­scape char­ac­ter or spe­cial qual­it­ies of the Nation­al Park. They are inap­pro­pri­ate with­in the Nation­al Park, or where out­side the Park they sig­ni­fic­antly adversely affect its land­scape char­ac­ter or spe­cial land­scape qualities”.

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item Item 8 24/06/2022

CON­SULTA­TIONS

NatureScot advice

1. In accord­ance with the NatureScot/​CNPA case­work agree­ment, NatureScot have provided CNPA with advice in rela­tion to the effects on the Nation­al Park, of the pro­posed wind farm both alone and cumu­lat­ively with oth­er exist­ing and con­sen­ted wind farms in the sur­round­ing area.

2. In rela­tion to the Wild­ness SLQ, NatureScot advise that the sur­round­ing hills (as illus­trated from rep­res­ent­at­ive view­points 2, 12 and 16) demon­strate the range of ridges, sum­mits and plat­eaux that can be exper­i­enced with­in the Strath­dearn hills, all con­trib­ute sig­ni­fic­antly to the wild appear­ance of this area of the Nation­al Park. The land­scape here exhib­its some of the char­ac­ter­ist­ics of the Wild­ness SLQ such as a per­cep­tion of rel­at­ive remote­ness, and while there are numer­ous obvi­ous signs of man­age­ment (such as hill tracks, both­ies and muir­burn, along with roads tran­sect­ing it, for example the B9007 and the A939), there still remains an over­arch­ing dom­in­ance of nature in the large scale land­scape. This SLQ is mod­er­ately well expressed here. Many of these hills are eas­ily access­ible from the main roads, with some less access­ible. The Strath­dearn hills provide the con­text for the north­ern extents of the Park, where wild­ness char­ac­ter­ist­ics of nat­ur­al­ness become increas­ingly more pre­val­ent as does the per­cep­tion of remote­ness across these hills in a west­ward direction.

3. From the inform­a­tion avail­able, it appears that the pro­posed devel­op­ment would be vis­ible across a swath of the north facing slopes, ridge lines and sum­mits of the Strath­dearn hills, where it would be viewed in com­bin­a­tion with the oper­a­tion­al Tom na Clach and Moy wind farms, and the pro­posed Leth­en wind farm.

4. In rela­tion to the Sur­round­ing hills SLQ, NatureScot advise that the pro­posed wind farm exten­sion would be loc­ated in the wilder, broad and roun­ded hills of the Dava Moor with­in the Open Rolling Upland Land­scape Char­ac­ter Type (LCT). There is a strong con­nec­tion between this LCT and the roun­ded hills, long ridges and glens of the Strath­dearn Hills with­in the Nation­al Park, which flow into one anoth­er over the north­ern bound­ary of the Nation­al Park and form the con­text of the Nation­al Park in this area. This area exhib­its key char­ac­ter­ist­ics of the Sur­round­ing hills SLQ; the smooth roun­ded form of these heath­er clad hills with their sud­den unex­pec­ted crags, screes, gul­lies, glens and wild appear­ance, and the rel­at­ive remote­ness exper­i­enced from these sur­round­ing hills are attrib­utes which are all well expressed in this area, under­pin­ning this SLQ.

5. While the oper­a­tion­al Tom na Clach (125m blade tip) and Moy (126.5m blade tip) wind farms are vis­ible from view­point 2 when look­ing north, they are largely screened from view by the inter­ven­ing sur­round­ing hills land­form and are of a scale which can be absorbed by this highly sens­it­ive land­scape. While the pro­posed devel­op­ment, when exper­i­enced from this area, would read visu­ally coher­ent as a single devel­op­ment with the oper­a­tion­al Tom na Clach wind farm, when assessed in com­bin­a­tion with the at applic­a­tion Leth­en wind farm, a lin­ear pat­tern of wind farm devel­op­ment would be formed that begins to encroach on the sur­round­ing hills, erod­ing the exper­i­ence and per­cep­tion of the wild char­ac­ter­ist­ics of these heath­er clad rolling hills, in particular

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item Item 8 24/06/2022

when exper­i­enced along the ridge line of the Strath­dearn hills, from with­in the Nation­al Park (demon­strated by rep­res­ent­at­ive view­points 2 and 12.

1. As illus­trated by the visu­al­isa­tions for view­point 2, there would be a c.120 degree exper­i­ence of wind farms with­in the imme­di­ate set­ting of the Nation­al Park (around 5km), with the pro­posed tur­bines numbered 1 – 3 and 6 extend­ing the phys­ic­al pres­ence of wind farm devel­op­ment over a series of ridgelines which form the pan­or­ama north towards the at applic­a­tion Leth­en wind farm. The intro­duc­tion of the pro­pos­al along­side Leth­en would rein­force wind farm influ­ence in the area and erode the per­cep­tion of nat­ur­al land­forms and wild­ness dom­in­at­ing. The res­ult­ant cumu­lat­ive effect would be the exper­i­ence of wind devel­op­ment encroach­ing on the con­text of the Nation­al Park in this area, visu­ally emphas­ising the invis­ible mapped bound­ary in phys­ic­al form.

2. As a res­ult of para­graphs 21 – 25, NatureScot advice is that the pro­pos­al itself, when viewed as an exten­sion to and in com­bin­a­tion with the oper­a­tion­al Tom na Clach wind farm, would not res­ult in sig­ni­fic­ant cumu­lat­ive effects on the above SLQs. How­ever, when con­sidered in com­bin­a­tion with the at applic­a­tion stage Leth­en wind farm, sig­ni­fic­ant adverse cumu­lat­ive effects on the Sur­round­ing hills and Wild­ness SLQs would be exper­i­enced from along the ridgeline of the sur­round­ing hills, which form the north­ern extents of the Nation­al Park.

3. The nature and sig­ni­fic­ance of the in com­bin­a­tion effects with Leth­en wind farm are how­ever such that NatureScot advise that the integ­rity of the Nation­al Park would not be compromised.

APPRAIS­AL

1. The policies of the NPPP and SPP set out how pro­pos­als out­with the bound­ary of the Nation­al Park should be con­sidered in terms of effects on the Nation­al Park.

2. Policy 3.3 of the NPPP sets out a test for con­sid­er­ing effects on the land­scapes of the Nation­al Park, in that large scale wind tur­bines are inap­pro­pri­ate out­side the Park where they ​‘sig­ni­fic­antly adversely affect its land­scape char­ac­ter or spe­cial land­scape qual­it­ies’. If a pro­pos­al fails policy 3.3, it would also be in con­flict with policy 1.3, which seeks to con­serve and enhance the SLQs.

3. Para­graph 212 of SPP sets out that ​“devel­op­ment that affects a Nation­al Park… should only be per­mit­ted where: a) the object­ives of des­ig­na­tion and the over­all integ­rity of the area will not be com­prom­ised; or b) any sig­ni­fic­ant adverse effects on the qual­it­ies for which the area has been des­ig­nated are clearly out­weighed by social, envir­on­ment­al or eco­nom­ic bene­fits of nation­al importance.”

4. In the policy con­text of the NPPP and SPP, con­sid­er­a­tion is required of the effects of the pro­posed devel­op­ment, on land­scape char­ac­ter and the SLQs, both alone and cumu­lat­ively with oth­er wind farms in the sur­round­ing area.

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CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item Item 8 24/06/2022

Pro­posed wind farm with exist­ing and con­sen­ted wind farms

1. When con­sidered in com­bin­a­tion with exist­ing and con­sen­ted wind farms, it is con­sidered the CNPA should not object to the pro­posed exten­sion to Tom nan Clach wind farm in com­bin­a­tion with exist­ing and con­sen­ted wind farms. This is because the exten­sion would not have sig­ni­fic­ant adverse effects on any of the SLQs, and there­fore would com­ply with NPPP policies 3.3a and 1.3, as well as Scot­tish Plan­ning Policy para­graph 212.

Pro­posed wind farm with exist­ing and con­sen­ted wind farms plus Leth­en wind farm

1. When con­sidered with exist­ing and con­sen­ted wind farms plus Leth­en wind farm (should it gain con­sent), there would be sig­ni­fic­ant adverse effects on two SLQs and so the pro­posed devel­op­ment would con­flict with the NPPP policies 1.3 and 3.3a. There­fore it is con­sidered that CNPA should object to the pro­posed wind farm devel­op­ment in com­bin­a­tion with exist­ing and con­sen­ted plus the pro­posed Leth­en wind farm.

RECOM­MEND­A­TION

That Mem­bers of the Com­mit­tee confirm:

• That CNPA do not object to the applic­a­tion for the pro­posed Tom nan Clach wind farm exten­sion in com­bin­a­tion with exist­ing and con­sen­ted wind farms, but
• should the applic­a­tion stage Leth­en wind farm gain con­sent, CNPA object, due to the cumu­lat­ive sig­ni­fic­ant adverse effects on the Sur­round­ing hills and Wild­ness Spe­cial Land­scape Qual­it­ies that would arise.